New guide for Philippine investigators chasing the financial footprints of wildlife traffickers

This comprehensive tool provides a summary of the Philippine Anti-money Laundering (AML) legal framework and practical guidance on basic financial investigations, evidence gathering and case development. 

Wildlife crimes are motivated by money, and most involve transactions with indelible records in financial systems. Financial investigation can be used to provide intelligence and evidence of criminality and support confiscation of assets. 

However, limited understanding of anti-money laundering regulations and possible pathways of leveraging financial investigation to complement standard law enforcement pose challenges. 

We know that financial investigations can seem daunting. The guide provides a clear starting point and walks investigators and prosecutors through the process"

     Ben Brock, co-author and TRAFFIC Senior Wildlife Crime Analyst 

“We hope that this guide motivates investigators to apply follow-the-money approaches.” 

The threat posed by environmental crimes was assessed by the Philippine National Money Laundering and Terrorist Financing Risk Assessment as “high risk”, with the number of environmental cases compounded by the amount of criminal proceeds and the absence of money laundering investigation.   

Violations of the Forestry Code R.A.7161, Mining Act R.A.7942, Wildlife Resources Act R.A.9147, National Caves Act R.A.9072, and Fisheries Code R.A.8440 were added to the list of predicate offenses for money laundering in 2013. To date, there has not been a successful money-laundering conviction in the Philippines for crimes predicated on breaking wildlife laws yet. 

Financial investigation techniques have been successfully used by law enforcement for many other crimes and is therefore a great opportunity to apply to environmental crimes too”

       Atty. Rainer P. Dela Fuente, lead author and CEO/Founder of AML Consulting PH

Following the money is more effective to pinpoint the masterminds behind serious wildlife trafficking compared to following commodities, which typically only leads to lower-level actors in the criminal networks. High-value wildlife crime is often organized and transnational, threatening transborder and national security, so using financial investigations to disrupt these networks is an important tool to have. 

This topic has long been a top capacity building priority for us. We warmly welcome this resource; it will cause a ripple effect in our department and beyond”  

        Atty. KC Panopio-Lofranco, Chief of the Litigation and Prosecution Division, Department of Environment and Natural Resources 

To complement use of the guide, on 21 July 2025, TRAFFIC and AML Consulting PH ran a webinar for over 150 law enforcers and prosecutors from 10 government agencies, to introduce the guide and field questions from participants.  

The guide builds on the Financial Investigations Training from last July 2024 organized by TRAFFIC together with the Philippines’ Financial Intelligence Unit, the Anti-Money Laundering Council, and AML Research Centre Asia Pacific.